VALP Main Modifications
Representation ID: 3633
Respondent: West Waddy
Legally compliant? Yes
The allocation of Shenley Park is unsound. It would extend Milton Keynes beyond a firm landscape ridge and have significant adverse landscape impacts, particularly on the southern parcel where Milton Keynes would effectively coalesce with Whaddon village, adversely impacting upon the
character of its Conservation Area. Alternative brownfield land is available on part of the FCC
Environment land at Bletchley Road, north of Newton Longville, which was a former Brick Works.
Redevelopment here would have a much lower environmental impact and could help preserve the separateness of Whaddon and Milton Keynes.
Allocate previously developed FCC Environment land at the former Brick Works in Bletchley Road,
north of Newton Longville for up to 600 dwellings and make a proportionate reduction in the size of
proposed allocation at Shenley Park, for the reasons outlined in the full representation.
VALP Proposed Main Modifications - Representations on behalf of FCC Environment:
Enter your full representation here:
Fundamental to a plan being justified and sound is that it is based on proportionate and up to date evidence that looks at reasonable alternatives (NPPF, paras 31 & 35). AVDC has singularly ignored this requirement, in allocating land at Shenley Park for at least 1,150 homes, 110-bed care home/extra care and associated
services & infrastructure. This is a large greenfield site, currently in agricultural use, parts of which are highly sensitive in landscape terms. The Council's 'Landscape & Visual Capacity Comparison Assessment,'
(2019), states that "Development within the western part of the northern parcel would be seen as extending
the development edge [of Milton Keynes] to within close proximity of Whaddon Conservation Area, to include
Whaddon Hall. Development within the southern parcel would represent an unacceptable extension of
development into the countryside and visible from the wider landscape," (para 5.1.25 of ED201A). Despite
this negative assessment the Council has nonetheless decided to allocate the whole site for development,
with the north-westernmost corner actually being contiguous with a part of the Whaddon Conservation Area.
The effect of this allocation would therefore, if adopted, be to cause the coalescence of Milton Keynes with
Whaddon and would also involve development crossing the landscape ridge that has hitherto defined the
built-up edge of Milton Keynes. The Final Housing & Economic Land Availability Assessment (HELAA)
version 4 (Jan 2017) also described the Shenley Park site as "highly sensitive in landscape/visual impact
terms so the scale, layout and form of development, will be very important," (Site ref: WHA001 p.253).
Development of Shenley Park would result in the loss of an extensive area of greenfield land (99ha) that
contributes to the character and beauty of the 'Whaddon Chase' countryside and is of some value for its
Despite the significant detrimental effects that would arise from this proposed allocation, the Council has not
made any assessment of the potential of the FCC Environment land at Bletchley Road, near Newton Longville. This site is located adjacent to the southern edge of Bletchley town and a substantial part was
formerly occupied by the Newton Longville Brickworks. Despite the fact that part of the former Brickworks site is allocated for employment-use redevelopment in the adopted Aylesbury Vale District Local Plan
(AVDLP) (2004) and another part has an extant consent for further employment-use redevelopment, surprisingly, the Council state in their 2017 HELAA that it is: "unsuitable - the site is in the open countryside separate from Newton Longville and Bletchley" and states that "development would be likely to have an adverse landscape & visual impact" (Site ref: NLV029).
That assessment conclusion is unsound on three grounds:
1. The site is adjoined by a ribbon of ten residential properties fronting Bletchley Road, which were originally associated with the former brickworks, and have the character of an urban terrace extending south from the built edge of Bletchley town and the soon to be reopened East-West rail line connecting
Bicester with Milton Keynes;
2. The Council has a long history of identifying the site as suitable for redevelopment. In 1995 the Council approved a Planning Brief for the Newton Longville Brickworks, which identified the former brickworks
as having: "potential for employment development" and also stated that: "this area could also be suitable for some low value/bad neighbour uses, provided they cause no significant nuisance to nearby residents" (p14). Subsequently, in the Local Plan 2004, parts of the former brickworks were allocated for employment use under policy RA.34. Subsequently, the Council granted planning permission for
erection of a single-storey modular office building with associated car parking and landscaping (15/00235/APP) on the southern part of the FCC Environment land; installation and use of a leachate treatment plant (09/20001/AWD); and planning permission has also been granted for the area
adjoining its northern boundary for temporary use for a construction compound incorporating storage area, site offices and car parking (18/04521/APP) associated with the re-opening of East-West rail;
3. The FCC site does not have the character of countryside, as it contains the remains of the former industrial use including access roads & hard standings. It is also very well screened by mature trees, 25 October 2019
so is not visible from the countryside to the south or west and would not therefore have a detrimental landscape impact. The assessment that the site is in the open countryside is therefore wrong. Indeed, this is confirmed by the
Council's own assessment of what it refers to as NLV024 in its 2017 HEELA, which relates to the part of the FCC Environment land furthest from Bletchley and therefore most likely to impact on the character of the countryside. That assessment describes the NLV024 land as suitable for employment and acknowledges that it has granted planning permission for 645m2 of employment in a modular office building in this location.
Unlike Shenley Park, the previously developed FCC Environment land in Bletchley Road is currently unused, so is not being used efficiently or most effectively. Therefore leaving it as it is would not accord with NPPF
advice, which states that planning policies should: "give substantial weight to the value of using suitable brownfield land within settlements for homes and other identified needs, and support appropriate opportunities to remediate despoiled, degraded, derelict, contaminated or unstable land" (para 118 c) and
to "promote and support the development of under-utilised land and buildings, especially if this would help to meet identified needs for housing where land supply is constrained," (para 118 d).
Despite the imperative need to make suitable use of the FCC Environment land opportunities at Bletchley
Road, near Newton Longville, the Council has not undertaken any proper assessment regarding its redevelopment potential and has not been willing to engage with FCC Environment, despite the clear NPPF requirement for early, proportionate and effective engagement. In order to ensure that it was considered as
part of any main modifications, FCC Environment made a site submission to the Council on 1st March 2019 and stated that they would welcome the opportunity to meet the Council to discuss the site. Further follow up letters were sent on 2nd April and 14th August 2019 requesting a meeting, and also enclosing an
illustrative masterplan demonstrating how 600 dwellings could be accommodated on the FCC land. Council Officers have thus far declined to respond positively to FCC's approaches.
Given that FCC Environment had identified the land as available for redevelopment within 5 years and is
ideally placed to meet identified needs in the local area, the site should have been assessed in the sustainability, transport, landscape, flooding, viability, ecology, water supply and heritage assessments that were subsequently undertaken on the Council's behalf in relation to the proposed main modifications and
the Housing and Economic Land Availability Assessment Update 2019 (ED204; ED205; ED206; ED208; ED210; ED211; ED214; RED215; ED216; ED217 & ED222). Regrettably, no consideration was given to the site in any of these documents. It is acknowledged that the majority of the site is currently a Biological
Notification Site. To achieve a net gain in biodiversity a large area would be left undisturbed to protect the
underlying geology and biodiversity enhancement areas are proposed in the south-west and north-east
corners of the site.
We note that the identified delivery of housing at Shenley Park is over the period 2024 - 2033. Over that
period, we consider that there would be potential to deliver up to 600 dwellings at the FCC Environment
Bletchley Road site, which would substantially reduce the amount of development needing to be provided
on greenfield land at Shenley Park. Any such reduction in size of the Shenley Park proposal would help
mitigate its landscape, transport and heritage impacts.
An illustrative masterplan of the potential development layout on FCC's land in Bletchley Road and how this
could be delivered in three phases delivering in total up to 600 dwellings is attached.
It is therefore suggested that the amount of development at Shenley Park should be reduced proportionately
by allocating the FCC Bletchley Road land, as identified on the attached illustrative masterplan, which would
- enable a landscape gap to be maintained, thereby preserving the separate identity of Whaddon
and preventing coalescence with Milton Keynes;
- protect the character, appearance and setting of the Whaddon Conservation Area;
- significantly reduce the amount of greenfield development needed on the sensitive southern parcel of the Shenley Park site; and
- enable the unused previously developed FCC Environment land of the former Brick works to be
brought back into active use.
Without these adjustments, we contend that the Plan is unsound as the proposed allocation of Shenley Park
does not constitute "an appropriate strategy, taking into account the reasonable alternatives, based on proportionate evidence", nor is it consistent with the NPPF in terms of making most effective use of land